G.R. No. 205307 - People vs. Golidan y Coto-Ong

Case Digest (G.R. No. 205307)
Expanded Legal Reasoning Model

Facts:

Incident and Charges

On January 20, 1995, in Baguio City, Philippines, a brutal criminal incident occurred involving multiple crimes: rape with homicide, murder, and frustrated murder.
The accused-appellants Eduardo Golidan, Francis Nacionales, and Teddy Ogsila, along with a fourth co-accused, were charged for separate but related crimes committed on the same day.
The crimes involved the rape and killing of a female babysitter ([AAA]), the murder of a one-year-old baby, Namuel Aniban, and the frustrated murder of a ten-year-old girl, Cherry Mae Bantiway, who survived the attack.

Information Filed and Indictments

On September 5, 1995, three separate Informations were filed by Assistant City Prosecutor Elmer M. Sagsago and approved by City Prosecutor Erdolfo V. Balajadia.
Each Information specifically charged the accused with:

Rape with homicide – involving forcible carnal knowledge of [AAA] resulting in her death due to intracranial hemorrhage from a skull fracture.
Murder – involving the fatal assault on one-year-old Namuel by hitting his head with a hard object.
Frustrated murder – involving the grievous injury inflicted on ten-year-old Cherry Mae, which nearly caused her death but was averted by timely medical intervention.

Testimony and Evidentiary Presentation

Prosecution Evidence

Testimonies from multiple witnesses, including:

Jennyline Aniban, mother of Namuel, and Muriel Bantiway, the grandmother, who described the events surrounding the discovery of the crime scene.

ii. Neighbors and police officers (e.g., SPO3 Undalos, SPO3 Ekid) who provided details on the behavior of the accused and observations at the scene.

The surviving victim, Cherry Mae Bantiway, despite suffering from cerebral palsy, was repeatedly identified in various police line-ups and through photograph arrays.
Expert testimonies from medical personnel such as:

Dr. Francisco Hernandez, Jr., and Dr. Divina R. Martin Hernandez regarding Cherry Mae’s capacity to perceive and recount the events.

ii. Dr. Vladimir Villasenor and Dr. Divina Hernandez on the physical injuries sustained by the victims and the consistency of the child’s testimony.

Evidence Relating to the Crime Scene

Autopsy reports detailing multiple external injuries on both [AAA] and Namuel.
Recovery of physical evidence such as a used one-liter Coca-Cola bottle and a wooden ashtray, both stained with blood.

Defense Evidence and Alibis

Each accused offered an alibi:

Eduardo Golidan testified he was engaged in helping tend to his family store and later traveled to Tabuk, Kalinga, although he returned briefly to Baguio.

ii. Francis Nacionales and Teddy Ogsila claimed they were at different locations (a restaurant and their residence, respectively) and were seen by other witnesses corroborating their whereabouts.

Repeated police line-up presentations where the accused were, at times, not positively identified by Cherry Mae, which the defense argued as indicative of her incompetency or the unreliability of her identification.

Judicial Proceedings Prior to Appeal

In the August 18, 1999 RTC decision, the accused were found guilty beyond reasonable doubt for each of the three crimes.
The RTC’s judgment was subsequently modified by the Court of Appeals on April 25, 2012, particularly in the imposition of penalties and monetary awards.

Procedural Background and Subsequent Developments

The trial court’s findings were based on a comprehensive gathering of testimonial, physical, and expert evidence.
On appeal, the accused raised multiple contentions regarding:

The competence and reliability of the child witness, Cherry Mae Bantiway.
The insufficiency of the evidence to establish their presence at the crime scene.
Alleged breaches in constitutional rights during the investigative process, such as the right to counsel.

The Office of the Solicitor General (OSG) filed a consolidated brief supporting the state’s evidence, emphasizing the legitimacy of inferring a conspiracy from the concerted and unified actions of the accused.

Issues:

Witness Competency and Identification

Whether Cherry Mae Bantiway, afflicted with cerebral palsy, was a competent witness capable of perceiving and accurately recounting the events.
The significance of her delayed and inconsistent identification in various police line-ups and photographic arrays.

Sufficiency and Credibility of Evidence

Whether the positive identification by the lone surviving witness was enough to overcome the defense’s contention of reasonable doubt.
The evaluation of physical and documentary evidence (e.g., autopsy reports, physical objects found at the scene) in corroborating the testimony of witness accounts.

Establishment of Conspiracy

Whether the acts committed by the accused demonstrated a common design to execute the crimes (thereby establishing conspiracy).
The legal sufficiency of inferring collective responsibility from the alleged concerted actions despite the absence of direct evidence of an agreement.

Alibi and Denial Defenses

Whether the defense’s alibi evidence was strong enough to negate the plausibility of the accused being present at the scene.
The weight to be given to the defense as compared to the multiple affirmative testimonials confirming the identification of the accused.

Procedural and Evidentiary Issues

Whether the investigative process, including police line-ups conducted without counsel, violated procedural safeguards.
The effect, if any, of the accused’s claims that their rights were infringed upon during the preliminary and investigative stages.

Ruling:

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Ratio:

(Subscriber-Only)

Doctrine:

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Case Digest (G.R. No. 205307) Core Legal Reasoning Model Expanded

Facts:

Case Digest (G.R. No. 205307) Expanded Legal Reasoning Model

Facts:

Issues:

Ruling:

Ratio:

Doctrine:

Case Digest (G.R. No. 205307)
Core Legal Reasoning Model

Expanded

Case Digest (G.R. No. 205307)
Expanded Legal Reasoning Model